Foreign Broadcast Content Disclosure Rulemaking

The FCC has adopted a proposed rulemaking that would require broadcast stations to disclose when they broadcast content that is sponsored or provided by foreign governments.  The NPRM delves into numerous issues that will ultimately inform broadcasters as to how diligent they will need to be in obtaining the information necessary for disclosure, how the disclosure requirements might apply to time brokerage or local marketing agreements, and how the proposal comports with the First Amendment.  We recommend a read through the rulemaking to see if any issues might impact how your station conducts operations and the steps that may be necessary to ensure compliance.